**9/9/15**

**U.S. Department of Transportation Docket Management System 1200 New Jersey Avenue SE**  **West Building Ground Floor Room W12**
**- 140**  **Washington, D.C. 20590 RE: Petition for Exemption Under Section 333 of the Federal Aviation**  **Administration Modernization**  **and Reform Act of 2012, public 112**
**- 95 Feb. 14, 2012,**  **Section 333 Petitioner:**  Daniel Thompson 26 Pearl Rd. Boxford, MA 01921
Dear Sir or Madam, Pursuant to Section 33 3 of the FAA Modernization Act of 2012 and 14 CFR Part 11, Daniel Thompson “petitioner” , hereb y applies for an Exemption from the listed Federal Aviation Regulations (FAR) to allow commercial Operations	of	Unmanned	Aircraft Systems ( UAS ) ,	so	long	as	such	operations	are	conducted	within	and	under the conditions and limitations outlined herein or as may be established by

the FAA a s required b y Section 333. These limitations provide for an equivalent or higher level of safety to operations under the current regulatory

structure specificall y, a safety enhancement to aerial imagery and videograph y conducted by manned aviation operations. The petitioner seeks to operate UAS for commercial purposes including (but not limited to) aerial photograph y, videograph y, cinematography , real estate and property inspection. The use of UAS for aeria l imagery and videography reduces the need for manned aircraft to perform the same function. Therefore it is in the best interest of the Public for the FAA to approve the r equested exemptions. Th e petitioner currentl y holds a Commercial Pilot Certificate and has been involved in aviation for 30 ye ars. He also has a background in photography and videography and appreciates the potential benefit s the use of Unmanned Aerial S ys tems brings to the community

.**The Specific sections of 14 CFR From Which You Seek Exemption and the Extent** 

**and Reason for Relief :**  **14 C.F.R Part 21.185** Airworthiness Certificate In consideration of the size, weight, speed and limited operating area associated with these aircraft and their operation, the Secretary of Transportation deter

mines that these aircraft meet the conditions of Section 333. **14 C.F.R. Part 45.23(b)** Display of marks UAS shall be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N

-Number) markings in accordance with 1 4 CFR part 45, Subpart C. Markings will be as large as practicable. **14 C.F.R. Part 61.113(a)** Private pilot privileges and limitations The FAA has found in previous grants of exemption that a PI C with a private pilot certificate operating a UAS would not a dversel y affect operations in the NAS or present a hazard to persons or property on the ground. **14 C.F.R. Part 61.133(b)** Commercial pilot privileges and limitations The FAA has found in previous grants of exemption that a PI C with a private pilot certificate operating a UAS would not adversel y affect operations in the NAS or present a hazard to persons or property on the ground. **14 C.F.R. Part 91.7(a)** Civil Aircraft Airworthiness In consideration of the size, weight, speed and limited operating area associated with this aircraft and its operation, the Secretary of T ransportation determined that these aircraft meet the conditions of Section 333. **14 C.F.R. Part 91.9(b)(2) &(c)** Civil Aircraft Flight Manual, Marking, and Placard Requirements The FAA has previously

determined that relief from these sections is not necessary

. Relevant materials may

be kept in a location accessible to the PI C in compliance with the regulations. **14 C.F.R. Part 91.103** Preflight Action As FAA approved flight manuals will not be provided for the aircraft an exemption will be needed. Normal procedures including but not limited to; reviewing weather, flight battery requirement, landing and takeoff distances, along will all of those found in attachment "DJ I Pilot Training". An equivalent level of safety will be provided by preflight protocol (see attachment) to properl y match the machine.**14 C.F.R. Part 91.109(a)**

Flight Instruction A ll flight training will be provided through procedures specified in Training Instruction (see attachment) during dedicated training sessions. Based on previous decisions made by the FAA for UAS petitions regarding th is regulation.

**14 CFR 91.109** UAS and r emotel y piloted aircraft do not have fully functional dual controls. Flight control is achieved through the use of a control box that communicates with the aircraft via radio communications. The equivalent level of safety is provided because neither a pilot nor passenger will be carried in the aircraft, and by the speed and size of the aircr aft. **14 CFR 91.113 (a) and (b)** The petitioner can achieve an equivalent level of safety as achieved b y current regulations because the UAS does not carry pi lot or passenger. While helpful, a pilots' license will not ensure remote control piloting skills. **14 C.F.R. Part 91.119(c)** Minimum Safe Altitude Aircraft will be operated below 400 AGL, but not over congested areas. **14 C.F.R. Part 121** Altimeter Settings The proposed aircraft have a barometric altimeter and GPS derived altitude capabilities. The petitioner recommends that the altimeter be set to zero feet AGL rather than local barometric pressure or field altitude before flight. Considering the limited altitude of the proposed operations. **14 C.F.R. Part 91.151(a)** Fuel Requirements in VFR Prior relief has been granted for manned and unmanned aircraft to operate at less than prescribed minimums. **14 C.F.R. Part 91.203(a) and (b)** Certifications Required Original	intent	of	these	regulations	was	to	display	an	aircraft’s airworthiness, certification	and registration documents so they would be easily

available to inspectors and passengers. Based on the FAA Section 333 of the Reform Act, authorizes the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability , and proximity to airports and populated areas of the particular UAS. In all cases, an anal ysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and under the conditions proposed will be at least as safe, or safer, than a conventionalaircraft (fixed wing or rotorcraft) operating with an airworthiness certificate without the

restrictions and conditions pr oposed. **14 C.F.R. Part 91.405(a)** Maintenance Required Given these section only

apply to aircraft with an airworthiness certificate, theses sections do not apply

to this applicant. As a safet y precaution, operator will perform preflight inspections and ens ure UAS is in working condition before initiating each flight. **14 C.F.R. Part 91.407(a)(1)** Operation after Maintenance Given this section only

applies to aircraft with an airworthiness certificate, theses sections do not apply to this applicant. As a safe ty precaution, operator will perform preflight inspections and ensure UAS is in working condition before initiating each flight. **14 C.F.R. Part 91.409(a)(1) and (2)** Inspections Given this section only

applies to aircraft with an airworthiness certificate, theses sections do not apply

to this applicant. As a safet y precaution, operator will perform preflight inspections and ensure UAS is in working condition before initiating each flight. **14 C.F.R. Part 91.417(a) and (b)** Maintenance Records Given this sect ion only

applies to aircraft with an a irworthiness certificate, it does not apply to this petitioner . As a safety precaution, operator will perform preflight inspections and ensure UAS is in working condition before initiating each flight. The petitioner is seeking relief from all FARs above preventing applicant from conducting cost effective aerial imagery services taken at levels less than 400ft, at a speed less than 33 mph, and with a maximum flight	time	of	25	minutes. The proposed UAS meet the definit ion of "small unmanned aircraft s ys tem" found in section 333 "The Reform Act". In order to obtain high quality photograph y and video the UAS will be used at speeds much less than it's top speed of 33 mph. Due to the UAS being battery

powered there ar e no c ombustible fuels onboard. Maximum flight time for this particular class of UAS is 2 0 minutes (approximate) battery life, flights to be terminated with 25% battery life remaining. Given the size, weight, speed, and limited operating area associated with the aircraft to be utilized. **How This Request Would Benefit the Public and Not Adversely Affect Safety :**   O perations of UAS to perform aerial imagery and videography

will reduce risk to life and property

by decreasing the need to operate manned aircraft to perform these tasks.
 Battery

- powered UAS serve as safe and efficient alternatives to the manned aircraft commonly

utilized to conduct aerial imagery and videography

. Also, theflight data, inspection results, recorded observations and lessons learned from these operations will be compiled to further enhance its current safety program.  The petitioner proposes that the exemptions requested herein appl y to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safet y to operations under the current regulatory structure because the proposed operations represent a safety enhancement to aerial imagery and videography conducted b y manned aircraf t.
 Reduction in gas emissions associated with powered flight.
 Improvement upon cost efficiencies associated with manned flight.
 National policy

set by Congress favors early

integration of UAS into the NAS in controlled, safe, working environments such as those proposed in this petition. In addition, the public also has an interest in reducing the hazards and emissions associated with alternate use of helicopters to conduct similar operations. **Privacy :**  All flights will be conducted in accordance with any a nd ALL federal, state and local laws regarding privacy **Proposed UAS for Commercial Applications :** 

 DJISpreading Wings S1000 o http://www.dji.com/product/spreading

- wings

- s1000/spec
 DJI Inspire 1 o http://www.dji.com/product/inspire

- 1/spec
 DJIPhantom 3 o http://www.dji.com/product/phantom

- 3/spec
 DJI Spreading Wings EVO S800 o http://www.dji.com/product/spreading

- wings

- s800

- evo/spec
PI C will operate UAS in safe manner that will not pose threat to person or property and with assistance from a visual observer (VO) If the UAS loses communications or loses its GPS signal, it will return to a pre

determined location within the planned operating area and land or be recovered in accordance with the operating documents. **Visual Observer:** All operations will utilize a visual observer (VO). The VO may be used to satisfy

the VLOS requirement as long as the PIC alway s maintains VL OS capability . The VO and PI C will be able to communicate verbally at all times. Electronic messaging or texting will not be permitted during f light operations. The PI C will be designated before the flight. The PIC will not transfer his or her designation for the duration of the flight. The PI C will ensure that the VO can perform the functions prescribed in the operating documents. The VO will no t perform an y other duties beyond assisting the PI C with seeing and avoiding other air traffic and other ground based obstacles/obstructions and isnot permitted to operate the camera or other instruments.

**Maintenance:** The petitioner will carry

out maintenance, inspections, and record keeping requirements, in accordance with the manufacturer operating documents and manuals. Maintenance, inspection, alterations, and status of replacement/overhaul component parts will be noted in the aircraft records, including total time in service, description of work accomplished, and the signature of an authorized person before returning the UAS to service. **Flight Operations:** 1. Flights will be operated in the line of sight of the operator 2. Flights will be te rminated at an y time weather conditions dictate 3. Flights will be operated at 4 00 feet AGL or less 4. Crew will be at a minimum of operator ( PI C) and an observer and/or camera operator (VSO) 5. Operator and crew will remain in cont act during the flight operation 6. The UAS op erator will perform a pre - flight check of the flight area 7. R equired F AA clearances will be obtained and distances from airports strictly observed. 8. All UAS will have the capability operator with the auto return function checked and working. 9. When operated in conjunction with fishing vessels in the gulf, a chase boat will be assigned to operate the UASs at a safe distance from the main fishing boat. 10. Flights will only

operate in VFR conditions. 11. UASs have a function on the control to tell operator the distance aw ay from the operator and its battery

power remaining. 12. Flight team will communicate b y voice and the use of two

- way radio if the area is too big to hear voice from all team members. 13. When operating over or near water the UASs will be equipped with flotation devices so that recovery

can be made as to prevent lithium battery exposure to the water table.
Thank you for your consideration and attention to this request. Sincerel y,

Daniel Thompson 26 Pearl Rd. Boxford, MA 01921